Attachment 2 - Statement of Work - 70Z03826QB0000049.pdf
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- Solicitation number
- 70Z03826QB0000049
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This is a Statement of Work (SOW) for Generator Control Unit (GCU) repairs under USCG contract 70Z03826QB0000049. The contractor shall provide all necessary parts, materials, labor, tooling, test equipment, and facilities to evaluate and repair GCU components at the contractor's facility or USCG-approved facility compliant with 14 CFR 145.103. Repairs must be performed in accordance with Original Equipment Manufacturer (OEM) Component Maintenance Manuals (CMM), USCG approved engineering changes, and FAA Advisory Circular AC 43-4B for corrosion control. Firm Fixed Price (FFP) repairs under CLIN 0001 shall include replacement of all systematically changed parts per the CMM. Alternate replacement parts require written notification to the Contracting Officer (KO) with evidence of OEM or USCG approval. Components determined to have "No Fault Found" after visual and functional inspections qualify for a T&E fee under CLIN 0002. Beyond Economical Repair (BER) items are authorized the T&E fee under CLIN 0002, with only the KO authorized to make BER determinations.
The contractor must maintain USCG SRR Engineering authorized repair facility certification throughout contract performance and provide ten (10) man-hours per quarter of technical support labor at no additional cost. All repaired components must be tagged with DD Form 1574 Serviceable Condition Code Tag and accompanied by failure data reports including NSN, P/N, serial number, nomenclature, repair date, and parts replaced. Quality assurance requirements mandate ISO 9001 or AS9110 certification, establishment of an inspection system per FAA and DOD procedures, and provision of an Acceptance Test Plan for government review. Components must be thoroughly cleaned per USCG-approved procedures to remove hazardous dust prior to return. The contractor shall maintain Component Repair Records (CRR) for S/N tracked components per ACMS procedures and notify the KO within five business days of receipt confirmation. Accelerated turn-around-time and AOG (Aircraft on Ground) situations require written authorization via task order modification with reimbursement for additional labor and expedited freight costs. Warranty coverage extends up to twelve months from installation date.
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GENERATOR CONTROL UNIT (GCU) REPAIRS
STATEMENT OF WORK (SOW)
70Z03826QB0000049
Attachment 2
1.0 SCOPE
1.1 The United States Coast Guard (USCG) Aviation Logistics Center (ALC) Short Range Recovery (SRR) product line has a requirement for the Generator Control Unit (GCU) test and evaluation (T&E) and repair. The Contractor shall provide all necessary parts, materials, labor, tooling, test equipment, and facilities to evaluate and repair the components listed in the Schedule. The Contractor shall provide technical support services, support product improvement efforts, and provide updates to Technical Orders. Work under this contract shall be performed at the Contractor’s facility.
2.0 APPLICABLE DOCUMENTS
2.1 Government Documents. The following specifications, standards, and handbooks of the latest revision at the date of the original release of this specification listed below form a part of this specification to the extent specified herein.
2.1.1 USCG Documents
2.1.1.1 USCG Technical Orders that support components set forth in the Schedule. Copies may be obtained by written request and approved by the Contracting Officer (KO).
2.1.1.2 USCG Approved Engineering Changes
2.1.2 Federal Aviation Administration (FAA) Advisory Circulars (AC)
AC 43-4B Corrosion Control for Aircraft 11 Sep 2018
2.1.2.1 A copy of these circulars are available at www.faa.gov.
2.2 Military Standards
MIL-STD-2073-1 Standard Practice for Military Packaging 27 June 2024 Revision E Notice 1
2.3 Occupational Safety and Health Standards (OSHA)
1910.1025 Lead
1910.1026 Hexavalent Chromium
1910.1027 Cadmium
2.3.1 A copy of these standards are available at www.osha.gov.
2.4 Applicable Commercial Documents
2.4.1 The Contractor must have access to the most current editions of the Original Equipment Manufacturer (OEM) Component Maintenance Manual (CMM) and all other applicable documents, manuals, and technical specifications for the components set forth in the Schedule.
2.5 Precedence. In the event of a conflict or ambiguity, the following order of precedence among documents shall govern:
a. USCG specifications and procedures, including this SOW and referenced documents.
b. OEM specifications and procedures
2.6 Section References. Within this SOW, references to a given section number shall imply reference to all subsections. Where a group of sections is referenced, such as Section 3.1.1 through 3.5, the word inclusive after Section 3.5 is implied whether actually stated.
3.0 REPAIR REQUIREMENTS
3.1 Repair of Generator Control Unit (GCU). Components shall be repaired for the specific fault for which they were returned. A DD Form 1577-2, Unserviceable (Reparable) Tag-Material, or CG-1577-A (11-90), Unsatisfactory Report Tag, will be attached to each non-ready for issue (RFI) item describing faults. The Contractor shall perform all repair activities IAW with the OEM’s technical requirements and the USCG approved engineering changes identified in section 2.1.1.2 of this SOW. The Contractor shall perform an inspection and correct deficiencies found. This shall include, but is not limited to, replacement of missing or broken parts and the removal of any foreign matter or corrosion. Firm Fixed Price (FFP) repairs are identified in the Schedule as CLIN 0001 and subsequent Option Period CLINs.
The FFP repair shall include replacement of all systematically changed parts as required IAW the
CMM.
Alternate replacement parts shall satisfy all form, fit, and function requirements of the original P/N and must have clear traceability back to the manufacturer per 14 CFR 145.109. The Contractor shall provide written notification to the KO when an alternate replacement part will be used. This written notification shall identify the P/N, unit price, manufacturer, and shall include evidence of OEM or USCG approval to use the alternate part as part of the repair process. Authorization to use an alternate replacement part will be provided by a modification to the applicable task order.
3.1.1 Work under this contract shall be performed at the Contractor’s facility or USCG approved facility. The facility shall meet all requirements of 14 CFR 145.103. The Contractor shall provide all necessary parts, materials, labor, tooling, test equipment, and facilities to evaluate and repair the components listed at the firm-fixed prices listed in the Schedule. The Contractor shall perform all repairs IAW applicable OEM CMM, other repair specifications in lieu of an applicable CMM, and/or applicable test/acceptance criteria. Any deviations must be approved by USCG. Original design or functional capabilities of the end item and parts thereof shall not be changed unless authorized or directed by the requirements of this SOW.
3.2 Test and Evaluation (T&E)/No Fault Found. If, after visual and functional inspections, an item is found to meet manufacturer's minimum performance specifications and is considered to be RFI, the item shall be classified as “No Fault Found”. The Contractor will be allowed the firm fixed price for T&E fee only identified as CLIN 0002 and subsequent Option Period CLINs in the Schedule. If the component is Beyond Economical Repair (BER) it shall be IAW with section 3.3. The parts shall be marked "RFI” or “BER” and returned to ALC.
3.2.1 All parts must be thoroughly cleaned IAW applicable USCG SRR Engineering approved cleaning procedures to ensure they are as free as practicable of all hazardous dust to include hexavalent chromium, cadmium, lead, etc., prior to being returned to ALC. ALC may take random samples of parts to ensure they are free as practicable of all hazards. Information on these hazards can be found in Occupational Safety and Health Standards 1910.1025, 1910.1026, and 1910.1027.
3.3 BER. Only the KO can determine a component BER. If an item is determined BER, the KO shall make a unilateral decision as to component disposition. The Contractor shall return all BER items to ALC. The Contractor shall not return any BER item until they have been notified by a written modification to the task order. The Contractor shall prepare a failure data report IAW section 4.2 in these instances. This report shall be included with the returned component.
When returning the item to ALC, the items shall be clearly marked as “BER” with the supporting evidence. The Contractor will be authorized the firm-fixed T&E fee established in CLIN 0002 and all subsequent option period CLINs.
3.4 Corrosion. During inspection and functional test, the presence of corrosion in a component shall constitute reason for a more thorough disassembly and inspection. Should corrosion be found, disassembly shall be made to the extent necessary to remove corrosion or replace the part, or parts, affected. Corroded parts shall be replaced, except in those cases where removal of corrosion from a part will not impair efficiency or safe operation of the part.
Corrosion removal and treatment of affected areas will be accomplished IAW manufacturer's specifications. If not addressed in the manufacturer's specifications, the Contractor shall use
FAA AC 43-4B.
3.5 Certifications. The Contractor, and all potential sub-contractors, shall maintain the following: USCG SRR Engineering authorized repair facility throughout the duration of the contract. The Contractor shall provide documentation to verify they have requested approval to service the components. The Contractor shall notify the Contracting Officer in writing, no later than ten (10) calendar days after any change, when the Contractor has a change in their certification status and shall disclose all facts relevant to the change.
3.6 Certificate of Conformance. The Contractor shall furnish a Certificate of Conformance IAW Federal Acquisition Regulation (FAR) Clause 52.246-15 (Apr 1984) for all components.
For repairs accomplished IAW USCG approved procedures, each component returned after repair shall be tagged with a DD Form 1574 Serviceable Condition Code Tag, completed in its entirety. Each repaired component returned to ALC must be tagged with DD Form 1574 Serviceable Condition Code Tag, completed in its entirety. This form shall be packaged with each component. FAILURE TO SUBMIT THE APPROPRIATE CERTIFICATES WILL RESULT IN NON-ACCEPTANCE OF THE DELIVERED ITEM. All non-accepted items will be returned to the Contractor at the Contractor’s expense.
3.7 Replacement Parts. Parts of a component found to be in a serviceable condition as a result of inspection and functional testing shall be reused. Missing parts and parts found to be defective or that require replacement by manufacturer’s instructions shall be replaced with parts meeting the manufacturer’s specifications and drawings. Replacement parts shall be new.
Repair of all items shall be IAW the USCG SRR Engineering approved repair procedures. The cost for parts that are replaced systematically during repairs and modification shall be included in the FFPs listed in the schedule as CLIN 0001 and subsequent Option Period CLINs.
3.8 Separately Priced Replacement Parts. The Contractor may designate certain high cost infrequently used parts as separately priced replacement parts prior to contract award. If these parts require replacement during repair authorization will be made by modification to the task order for use of the Separately Priced Replacement Part(s) or provide disposition instructions as necessary. The Contractor shall notify the KO within ten (10) business days after receipt of the components(s) when any of the separately priced replacement parts specified in the Schedule are required. The Government reserves the right to provide separately priced replacement parts as Government Furnished Material on an as-needed basis. The delivery schedule will be adjusted accordingly for any delay associated with requesting and obtaining the approval to utilize the specified separately priced replacement part(s). Separately priced replacement parts, if necessary, shall be listed under CLIN 0003 and subsequent option period CLINs.
4.0 DOCUMENTATION
4.1 Contractor Verification of Receipt of Components. Within five (5) business days following receipt of component(s), the Contractor shall provide written notification of the following to D05-DG-ALC-SRR-SUPPLY@uscg.mil:
a. Date of receipt of components(s).
b. Confirmation of serial number(s) (S/N) received; and
c. Applicable Task Order and line-item number
4.2 Failure Data Report. The Contractor shall submit a failure data report for each repaired component (including when no fault is found), which shall be attached to the packing slip and shipped with the repaired component. This report shall include National Stock Number (NSN), P/N, S/N, nomenclature, date of repair, contract number, task order number, line-item number, description of the repair failure, the Government’s reported failure, and a listing of parts replaced. The Contractor’s in-housework order may be used to satisfy this requirement if it includes the information requested above.
4.3 Replacement Parts Summary. Upon request by the KO, the Contractor shall submit electronically a summary listing all replacement parts utilized in the repair of each component.
The replacement parts listing shall include the contract number, task order number, Contractor's work order number, component S/N, nomenclature, replacement parts listed in numerical order and quantity of each used.
4.4 Asset Computerized Maintenance System (ACMS) Procedures. ACMS is the management information system used to schedule and record all USCG aircraft maintenance.
Tracked components will be shipped to the Contractor with a Significant Component History Report (SCHR).
4.4.1 SCHR. The SCHR records the maintenance history of S/N tracked components. The SCHR remains with its corresponding part until reinstalled on an aircraft or annotated “BER” and returned to the address specified in section 12.1. The SCHR for scrapped components shall be returned with the component. The Contractor shall retain a copy of the SCHR for ninety (90) business days.
4.4.2 Component Repair Record (CRR). The CRR records the maintenance performed on S/N tracked components by the Contractor and enrolls or removes components from ACMS when those components are scrapped, added to or removed from the USCG parts inventory. The Contractor is required to use the CRR provided with the component. Within five (5) business days following issuance of a Certificate of Conformance, one (1) copy of the CRR shall be emailed to the Contract Specialist administering the contract. The original copy of the CRR shall be packed with the component for return to the USCG. The Contractor shall retain electronic copies of the CRRs for the life of the component. The Contractor may request that their failure data report, described in section 4.2, be accepted to fulfill the CRR requirement.
4.5 Publications/Updates. Contractor shall use USCG SRR Engineering approved repair procedures to repair the components identified in the Schedule. If the Contractor determines that current approved repair procedures should be changed, a copy of the recommended changes shall be submitted to the KO for review and approval/disapproval by SRR Engineering.
5.0 UNUSUAL DAMAGE
5.1 The USCG intends that all components specified in the schedule will be shipped for repair within the firm-fixed prices established in the resulting contract. Occasionally, components may be received in a condition outside the confines of the SRR Engineering repair procedures. Those components may be determined Unusually Damaged. In order to be determined Unusually Damaged, a component must be received for repair and upon evaluation any one of the following conditions are discovered:
Obvious misuse Crash damage Acts of God
Only components meeting one or more of the above criteria may be considered as Unusually Damaged. Missing piece parts does not include the parts that are to be systematically changed out per SRR Engineering approved repair procedures; the USCG shall not be charged for these parts. All other components shall be repaired IAW the fixed repair prices established in CLIN 0001 and subsequent option periods of the Schedule.
5.2 Unusual Damage Reporting Requirements. When a component is processed for Unusual Damage Evaluation, the Contractor shall notify the KO in writing within fifteen (15) business days. The Government may request the Contractor to submit an inspection condition report, pictures of the damage, and a repair quote listing all parts and labor needed to return the component to serviceable condition that meets SRR Engineering approved repair procedure specifications. The quote shall include the task order number, line-item number, NSN, P/N, and S/N of the component. The hourly labor rate shall be charged at the firm-fixed rate established in the Schedule under CLIN 0004 and subsequent Option Period CLINs. The quote shall not include the work involved in the teardown and inspection, which will have already occurred, as this is covered by the firm-fixed prices specified under CLIN 0001 and subsequent Option Period CLINs in the Schedule.
The Contractor’s task obligation shall stop from the date of notification that an item has been determined to be a candidate for “Unusual Damage Evaluation.” The delivery obligation will be specified in the task order modification and will apply only to those items specifically addressed by the modification. The Contractor is obligated to deliver all other components not individually addressed by the modification under the original delivery date specified on the task order.
The KO shall either initiate negotiations for a firm-fixed repair price with the Contractor or if repair is not desired provide disposition instructions for the component. Authorization to proceed with repair work or disposition instructions if repair is not authorized shall be given via issuance of a task order modification. If a component is returned to the USCG in a disassembled condition, the Contractor shall be entitled only to the T&E Fee established in the Schedule of Supplies/Services under CLIN 0004 and subsequent Option Period CLINs.
6.0 TECHNICAL SUPPORT
6.1 Technical Support. The Contractor shall maintain a permanent presence in the United States, staffed with qualified, English speaking technical support personnel. The Contractor shall provide answers to basic questions from Government engineers at no additional cost to the Government. The Contractor shall provide up to ten (10) man-hours per quarter of technical support labor at no additional cost to the Government. In the event that a requested task cannot be completed within ten (10) man-hours per quarter, the Contractor shall immediately notify the KO and provide a preliminary estimate of the time and costs required for completion. This support shall be required throughout the contract period of performance. The Contractor will be responsible for tracking man-hours each quarter.
6.2 Technical Support Services. Upon receipt of a request for quote for a specific task, the Contractor shall prepare and submit a quote to the KO. This quote shall include a breakdown of hours, materials, and other costs associated with performance of the task. The labor rate in the Schedule (CLIN 0005 and subsequent Option Period CLINs) for technical support services will apply. Specific deliverables will be identified on individual task orders.
6.3 Product/Engineering Changes. The Contractor/USCG may develop designs and/or include processes that will improve the reliability, maintainability, or operational performance of the Generator Control Unit (GCU). These may be provided to the KO for consideration and approval. A quote shall also be provided that reflects the Contractor’s costs and an incremental charge to be assessed each time the product change is incorporated into the component. The quote shall include a breakdown of labor hours, material, and other costs. The labor rates will be as specified in CLIN 0006 and subsequent Option Period CLINs. Authorization for the Contractor to incorporate the change will be by a modification to the contract and applicable task orders. The Contractor shall not incorporate proposed product changes prior to receipt of written authorization from the KO.
6.4 Service Bulletins. The Contractor shall provide an electronic copy of all service bulletins to the KO within three (3) business days of receipt of service bulletins (or other instructions) that may affect Government components. The KO will notify the Contractor in writing when incorporation of mandatory or optional service bulletins is required. Within thirty
(30) business days following receipt of notification from the KO, the Contractor shall submit a detailed quote for incorporation of service bulletin(s). This quote shall include a listing of replacement parts and/or materials required, the time needed to affect the modification, a price breakdown of each part, and the number of labor hours required. The Government will normally incorporate all mandatory service bulletins. The labor rate will be as specified in the Schedule as CLIN 0007 and subsequent Option Period CLINs.
7.0 QUALITY ASSURANCE PROVISIONS
7.1 Responsibility for Inspections and Tests. The Contractor shall establish an inspection system IAW FAA and/or DOD procedures for all components. The Government reserves the right to review the Contractor operation and/or facilities at any time during the period of the contract.
7.2 Testing. The Contractor shall ensure that the acceptance testing required for repaired components include verification of repair of the fault for which it was returned, and other testing as required to verify RFI status. The Contractor shall provide a copy of their Acceptance Test Plan (ATP) to the Government for review with their quote. Acceptance testing for repaired Generator Control Units (GCUs) shall be conducted IAW the Government reviewed ATP. The Contractor shall make available to the Government all acceptance test results and, as applicable, discrepancy reports with corrective actions taken for each GCU. The ATP may be incorporated into the manufacturer’s publications.
7.2.1 Changes to Repair Test Procedures. The Contractor shall provide written notification to the KO no later than fifteen (15) business days following changes to applicable OEM Repair ATPs. The Government reserves the right to verify that the Contractor’s procedures are adequate to ensure the delivery of RFI parts.
7.3 Quality Control System. The Contractor is required to be certified and maintain a quality system that complies with the requirements of International Organization for Standardization (ISO) 9001 Quality Management Systems – Requirements, Aerospace Standard AS9110, or equivalent. The Contractor is responsible for performing or assuring all inspections, tests, and calibration necessary to substantiate that the goods or services furnished conform to USCG’s requirements. The Contractor shall take prompt action to correct conditions that have or could result in goods or services that do not conform to contractual requirements. Records of conformance shall be maintained on file at the Contractor’s facility and made available or provided for review by USCG upon request. USCG reserves the right to conduct surveillance at the Contractor’s facility to verify the existence, adequacy, and effectiveness of the quality system. Upon request of USCG, the Contractor shall forward a copy of their current certification and Quality Assurance Manual for review.
7.4 Inspection and Acceptance. Inspection and acceptance shall be performed at destination by Government personnel for count, condition and properly completed documentation. Components determined to be non-RFI upon installation may be returned to the Contractor with a Product Quality Deficiency Report (PQDR) for repair at no additional cost to the Government. Inspection and acceptance deficiencies may delay or cause rejection of invoice payments. Equipment found to have operational deficiencies will be reported on standard form "SF 368", PQDR, to the Contractor for investigation. The Contractor shall report findings of the investigation to the KO, within twenty (20) business days after receipt of the component.
7.5 PQDR. Repaired Generator Control Units (GCUs) found to have deficiencies will be returned to the Contractor for investigation under a no-cost warranty repair task order per CLIN 0008 and subsequent Option Period CLINs. The task order will include a copy of the PQDR outlining the component deficiency. The Contractor shall report findings of the investigation to the KO within fifteen (15) business days after receipt of the component. If agreed upon between parties that the component’s deficiencies are not related to previous repairs completed by the Contractor, the Contractor’s report of findings shall include a detailed quote that includes a complete breakdown of parts and labor necessary to return the component to serviceable condition. The KO will either initiate negotiations for the work or accept the Contractor’s quote and issue a modification to the task order authorizing and incorporating pricing for the repair work. The terms and conditions of the base contract including delivery obligations shall apply to all no-cost warranty repair task orders.
7.6 Requirements for Supplier Changes.
7.6.1 The Contractor shall, immediately upon discovery, notify and disclose conditions to the KO of any event, supply change, material change, supply malfunction, counterfeit/suspect parts or materiel, defect or non-airworthy condition of any product, component, or repaired item found to potentially cause non-conformity to the original specifications of this contract. The Government reserves the right to inspect any non-conforming product or component. Therefore, the Contractor shall obtain written approval from the KO prior to the disposition of any non-conforming product or component.
7.6.2 The Contractor’s quality control manual shall address in detail the Contractor’s risk management, test, inspection, non-conforming product, and counterfeit/suspect parts processes.
7.6.3 The Contractor shall immediately notify the KO of any changes that potentially have an impact on the product. Changes may include but are not limited to products, processes, materiel, supplier sources, manufacturing facility location, or personnel qualifications.
Upon notification of the change, the USCG will approve or deny the change. Facility location changes may require the Government to perform a facility inspection. The Contractor shall allow the Government access to all applicable areas of the Contractor’s facilities to ensure compliance with contractual requirements. In the event, the change is not approved by the USCG, the contract or task order may be cancelled/terminated IAW the FAR.
7.6.4 The Contractor shall retain all records IAW FAR 4.7, Contractor Records Retention. The Contractor shall be required to permit Government access to applicable records retained at any level of the supply chain.
7.6.5 Unless otherwise specified, the Contractor shall flow down all requirements in this contract to their supply chain, to include all subcontractors and suppliers.
8.0 SPECIAL INSTRUCTIONS
8.1 Accelerated Turn-Around-Time and Delivery. Only the KO may request and authorize an accelerated turn-around-time and delivery if needed by the Government for delivery to the USCG, ALC Receiving Department, 1664 Weeksville Rd., Elizabeth City, NC 27909. In the event an accelerated turn-around-time and delivery is needed, which the Contractor can meet, the Contractor shall be entitled to compensation for additional labor hours and expedited freight costs necessary to complete performance earlier than the turn-around-time and delivery schedule established in the Contract. After receiving a written request from the KO for an accelerated turn-around-time and delivery, the Contractor shall provide a written response within one (1) business day advising if an accelerated turn-around-time and delivery can be accomplished and include any additional costs necessary for the accelerated performance. Accelerated performance may be authorized in writing via a task order modification. If the Contractor accelerates turn-around-time and delivery on its own initiative in order to meet the delivery schedule established in the contract task order, the additional costs are not recoverable from the Government.
8.2 Aircraft on Ground (AOG) Situations. An AOG situation necessitates a special schedule and requires accelerated repair completion and expedited delivery to the applicable USCG Air Station. In the event an AOG status occurs as a result of a lack of any of the components specified in the schedule, the Contractor will be notified by the Government in email or by phone of the AOG situation and the applicable USCG Air Station and will be requested to provide a written response within twenty-four (24) hours of the request. The Contractor’s response shall provide 1) status of the component(s) needed to satisfy the AOG condition that includes what USCG items in-house for repair are closest to completion under normal working conditions and 2) an estimate of the labor hours needed to accelerate repair completion. The accelerated repair work will be authorized via a task order modification in conjunction with mutually agreed upon prices, delivery, and shipping costs reimbursement for next day delivery to the applicable USCG Air Station.
In the event of an AOG situation, the task order and applicable task order CLIN will be modified to reflect the USCG Air Station’s delivery address and the applicable USCG Requisition Number.
The Contractor shall be required to ensure the Requisition Number is included on shipping/delivery tickets so that the Material Receipt can be processed by the applicable USCG Air Station receiving personnel.
8.3 Aircraft Accidents and Incidents. Disposition of evidence, including Generator Control Unit (GCU) components, involved in aircraft accidents or incidents shall be IAW current Government investigation procedures. These procedures are IAW and at the direction of the National Transportation Safety Board whose rules and regulations delegate to the Government such authority as is appropriate. Contractor participation in these proceedings will be determined by the president of each accident or incident board and directed by the KO. Investigations of Generator Control Unit (GCU) failures undertaken outside of formal proceedings will be a cooperative effort between Contractor and the Government.
9.0 WARRANTY
The Government may accept the Contractor’s standard commercial warranty, up to 12 months for repairs. All assets returned under warranty shall be tested IAW Section 7.2. The warranty shall begin from the date the component is installed on the aircraft and extend for up to twelve
(12) months after installation unless corrosion or unusual damage is found on the outside of the component.
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